The privacy practices of this Workspace Privacy Policy apply to our services available under the domain and subdomains of www.castlelake.com (the "Workspace"). We recognize that privacy is important to our users, so we design and operate our Workspace with the protection of your privacy in mind. This Workspace Privacy Policy outlines the types of personal information we may gather when you visit our Workspace or use our services, as well as some of the steps we take to safeguard it. Please read this Workspace Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information. By visiting the Workspace, you agree to be bound by the terms and conditions of this Workspace Privacy Policy. If you do not

By accepting the Workspace Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Workspace Privacy Policy. This Workspace Privacy Policy is incorporated into and subject to the Terms of Use. This Workspace Privacy Policy is effective when accepted by new users.

Overview

We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Workspace is protected by those policies and procedures. Generally, we collect non-public personal information about our clients, investors and third parties from the following sources:

  • Information received from investors or prospective investors on subscription documents or other related documents or forms, including any information we collect on the Workspace; and
  • Information about a transaction reviewed or entered into by the funds or accounts Castlelake manages, their respective affiliates, or others.

Our policy is that:

Castlelake takes precautions to maintain any nonpublic personal information about prospective, existing or former investors in funds or accounts it manages or has managed to anyone, except as permitted by law and regulation. Castlelake takes similar precautions to ensure that third party transactional information is not inappropriately disclosed to any other person.

Castlelake restricts access to nonpublic personal information to those employees and agents who need to know that information in order to provide services to Castlelake, the funds or accounts it manages. Castlelake maintains physical, electronic, and procedural safeguards to safeguard the nonpublic personal information and which Castlelake believes are adequate to prevent unauthorized disclosure of such information.

Collection of Information

In general, you can browse the non-password-protected sections of the Workspace without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit the Workspace. This information may include your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We use this information to operate, develop and improve our services.

We also may use data collection devices such as "cookies" on certain pages of the Workspace to help analyze our web page flow, measure effectiveness, and promote trust and safety. "Cookies" are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a "cookie". Cookies can also help us provide information that is targeted to your interests. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Workspace and you may be required to reenter your password more frequently during a session. We use cookies to better understand how people interact with us.

Use and Disclosure of Information

We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use. If you apply for a password, we use that data to determine whether you are an accredited investor and have sufficient sophistication, investment experience and wealth to receive information about certain investment options. We may use your information to send correspondence and perform services on your behalf in connection with investment related activities.

You agree that we may use personal information about you to analyze Workspace usage, improve our content and customize the Workspace's content, layout, and services. These uses improve the Workspace and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Workspace.

In connection with providing our services, it also may be necessary for us to share information with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios. In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require such third parties to treat your private information with the same degree of confidentiality that we do. In some instances, the third-party service provider may collect information directly from you. In these cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to a service provider directly, their use of your personal information is governed by their applicable privacy policy.

We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not described in this Workspace Privacy Policy. For example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Workspace. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

Control of Your Password and Personal Information

If you apply for a password to access password-restricted areas on the Workspace, you must provide to us such information as Castlelake may reasonably request.

You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your user name or password to access or use any part of this Workspace. If your password has been compromised for any reason, you should contact us immediately for a new password.

You can review and change the information that you submit to us by contacting us at Investor.Relations@castlelake.com. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate.

On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy.

We will retain in our files the personal information you have asked us to remove from our active databases to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, you should not expect that your personal information will be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.

Security

Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, "firewalls" and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, "perfect security" does not exist on the Internet.

Conditions of Use

If you choose to visit the Workspace, your visit and any dispute over privacy is subject to this Workspace Privacy Policy and our Terms of Use, including limitations on damages. If you have any concern about privacy, please send a thorough description.

Changes to Workspace Privacy Policy

This Workspace Privacy Policy may change from time to time. We may amend this Workspace Privacy Policy at any time by posting the amended terms on the Workspace.